The Tax Court has agreed with the IRS and denied a charitable contribution deduction of $504,000 to taxpayers who donated a conservation easement to a qualified conservation organization but did not simultaneously obtain a subordination of the purchase money mortgage on the property. The Court said the taxpayers were not entitled to invoke the “so-remote-as-to-be-negligible” standard in determining whether they could claim the deduction. The Tax Code permits a charitable contribution for the donation of qualified easements to qualified conservation organizations but only if the easement is “permanent.” An easement is not considered permanent if it is subordinate to prior liens, including a...